RM-11306 Comments - use or steal as needed :-)

[steve_qix]

Comments filed with respect to RM-11306
Petition For Rule Making

Overview of Comments

Some of the goals proposed in RM-11306; specifically, the expansion of the service to allow new modes of operation, and the expansion of the existing phone bands, would be of benefit to the Amateur Service.

However, RM-11306 also seeks to impose severe and unreasonable restrictions on the Amateur Service in general, and on how specific modes of operation are used, by creating a complex matrix of bandwidth-based regulations that affect existing modes, where no new regulations of these modes are needed. 

The general theme of RM-11306 also suggests that innovation is only taking place in the Digital Communications arena.  This is a very narrow view, and does take into account the fact that innovation is taking place in other areas of the hobby. If RM-11306 were to be adopted, these other areas of experimentation and innovation could effectively be squelched.

With the modifications proposed herein, the (reported) major goals of RM-11306 – permitting of certain new modes of operation and expansion of the phone bands - can be realized without the undesirable negative side effects of other parts of the proposal.

Specific Items

1) The proposed Bandwidth Restrictions are not needed

As RM-11306 accurately points out on page 4, the Amateur Service is “fundamentally a technical service”.  It is not a commercial service, and therefore does not need, and should not have specific frequency response or “hard number” bandwidth restrictions, particularly with respect to existing modes and emission types.

Amateur operators have been operating under the current set of rules regarding phone, CW, RTTY and data operations for many years, and there is no need to re-regulate these modes or operations by imposing a specific, numeric bandwidth to them.  Good practice has been quite successful for many years in keeping transmitted bandwidth in line with the particular operational mode.

The bandwidth of new, non-phone modes can be permitted under 
FCC Rule 97.307 f (2), applying to all non-phone emissions.
      
This should be sufficient to allow new modes to be freely deployed, and offer sufficient guidelines for operational and technical standards with respect to interference to other stations using currently existing modes.

Therefore, the following is proposed:

Amend section 97.305 as follows:

“(d) Uncategorized Emission Types: A station may transmit any emission not otherwise specified in this section, on any frequency where “Image” is permitted and if the frequency is authorized to the control operator’s license. The bandwidth of the emission shall be subject to Section 97.307 f (2).”

2) Sub-Band Reallocations

RM-11306 proposes elimination or reduction of some mode based sub-bands, and this makes sense, given the current usage of the HF bands.  There is significantly less CW / RTTY activity than phone activity, and an expansion of the phone band is a logical change.  However, for historical reasons (if nothing else), it makes sense to reserve some portion of the HF bands for CW and RTTY exclusively. 

Furthermore, as technology changes, there may be more operations that use automated or semi-automated transmissions of data.  Since it is not known at this time the extent to which these technologies will be deployed, nor do we fully understand the compatibility (or incompatibility) between these automated technologies and traditional Amateur uses (such as phone and CW), it makes sense to (possibly temporarily) restrict these operations to certain portions of the Amateur bands.  The Commission could consider a date, at which time and after an appropriate comment period, the restriction could be modified or eliminated.

The following modifications to section 97.305 are proposed:

A: The lowest 50kHz of the 80, 40, 20, 15, and 10 meter Amateur bands, and the lowest 25kHz of the 17 and 12 meter bands shall be specifically allocated for RTTY and data only, as currently defined in the regulations.  The remainder of these bands shall be allocated for all permitted emission types.

B: Automatic and Semi-Automatic transmissions shall be permitted in the following sub-bands (Note: all other modes are also permitted in these sub-bands):
   160 Meters: 1820-1850 kHz
   80 Meters:  3550-3700 kHz
   40 Meters:    7050-7150 kHz
   20 Meters:   14050-14150 kHz
   17 Meters:   None
   15 Meters:   21050-21200 kHz
   12 Meters:   None
   10 Meters:   28050-28500 kHz

      Suggestion: Perhaps a higher license class (maybe Extra Class?) should be
      required for automatic and semi-automatic transmissions.

3) Station Identification

The changes proposed in RM-11306 to section 97.119 (page 21, bottom section of RM-11306) make sense.

4) Automatically Controlled Stations

The changes proposed to section 97.221 (c) by RM-11306 make sense.  The changes proposed to 97.221 (b) are covered above.

Comments on the Amateur Service in general:

I have been an Amateur licensee since 1972, and have been actively engaged in experimentation and innovation involving radio since then.  The Amateur Radio service provides a practical, legal medium for deployment of these experiments and experimental transmitters, and for real-world use of the equipment.  For me personally, Amateur Radio was the training ground for a life long career in electronics and engineering.  I have personally mentored numerous people in the pursuit of knowledge on radio, electronics and engineering in general, and Amateur Radio has been the facilitating element. 

In addition to providing a public service with respect to emergency and other related communications, Amateur Radio provides the only freely available, long term medium for radio learning and experimentation with practical deployment and direct communication with others, many of whom share these technical interests, or are motivated to delve into the more technical aspects after “listening in” to related conversations. 

This unique opportunity for learning, innovation and experimentation with radio and electronics is unmatched by any other medium, and provides a significant benefit to the public, industry and the Nation as a whole.

Respectfully Submitted,

Stephen Cloutier
WA1QIX
Townsend, Massachusetts.

[kc2ifr]

Steve,
You write as well as u design.........IMHO u are THE MAN!!!!!! Im so happy u are part of the AM community!
Hows that for "sucking up?"

[W2INR]

Quit sucking up and post your comments Bill. You always have something to say

Very nice comments Steve, Thanks for commenting.

[steve_qix]

Quit sucking up and post your comments Bill. You always have something to say

Very nice comments Steve, Thanks for commenting.

Yeah, but I don't know if RM-11306 **SUCKS** is going to carry any weight with the FCC :-)  Seriously Bill - DO file comments.  Thanks
for the kind words, by the way - oh, you DO accept Paypal don't you 

Thanks and Regards,

Steve

[W1DAN]

Steve:

Very good post! Well thought out.

I agree that data must be allowed in some form. I am hoping it can be done with little compromize in all existing modes.

I wonder if the CW ops will get upset at your using the low end of the band?

My thought would be to re-allocate most of the Novice CW band for data (say 3.710-3.750, leaving 3.700-3.710 for the nostalgic CW op).

I commented on the FCC site anyway...

73
Dan
W1DAN

[WA1GFZ]

Steve,
The lower 70 KHz of the bands is prime fishing ground for CW. This would as bad as pushing AM to the top 70 khz of a band. This is why I am for no change myself having spent many years on CW. Stick data in the vast bad lands just below the voice bands. fc

[steve_qix]

Steve,
The lower 70 KHz of the bands is prime fishing ground for CW. This would as bad as pushing AM to the top 70 khz of a band. This is why I am for no change myself having spent many years on CW. Stick data in the vast bad lands just below the voice bands. fc

Hi Frank,

I agree totally !! :-)  This is what I tried to convey in my response.  The existing rules allow CW anywhere, and so does my proposal, as it makes no modification to the existing rules other than to modify the phone portion of the bands. My proposal simply shrinks the existing CW band to 50kHz (at least on 75 meters).  This keeps the CW ops where they are used to operating... but still allows them to go anywhere.

Do you think I should make an ammendment to my comments?  I want to be clear.


Oh, I have read almost all of the comments submitted.  Some of them are VERY good.. Did anyone read the one about the Ham Radio Militia?  It's 100 some-odd pages long!!!! I didn't read all of THAT one.

Regards,

Steve

[WA1GFZ]

Steve,
As a CW operator I don't think I ever strayed more than 100 khz above the bottom edge of the band. I suppose 100 khz is enough room. But then I listen to the phone bands and wonder why some idiots should get more bandwidth. 3500 to 3700 for cw and data and 3700 to 4000 for voice is more than fair in my book. I liked the idea of the incentive license.
I have a real problem making it a free for all. Some AMers want that but I can't agree.
Just becasue you own a rice box that costs 4 grand does not make you special and just because you have figured out how to connect an audio amplifier to an RF final through a transformer doesn't make you special either.

lover of spark!

[steve_qix]

Steve,

*snip*
I have a real problem making it a free for all. Some AMers want that but I can't agree.
Just becasue you own a rice box that costs 4 grand does not make you special and just because you have figured out how to connect an audio amplifier to an RF final through a transformer doesn't make you special either.

lover of spark!

I definitely agree on the incentive licensing!  I think the test should be HARDER, not easier.  The OLD Advanced and Extra tests were HARD, and there were plenty of hams.

Talk later and Regards,

Steve

[kc2ifr]

and just because you have figured out how to connect an audio amplifier to an RF final through a transformer doesn't make you special either.

Hey...hey....hey........I resemble that remark....

[W3LSN]

As a CW operator I don't think I ever strayed more than 100 khz above the bottom edge of the band. I suppose 100 khz is enough room. 3500 to 3700 for cw and data and 3700 to 4000 for voice is more than fair in my book.
I have a real problem making it a free for all.

I think Steve's comments are very well reasoned and thought out. I just wish I had the time to frame my own comments so nicely.

FWIW I filed my comments a week or so ago, pro-11305 and against 11306, although I have some misgivings about each petition.

Although I've been a ham for 30-years I've been QRT for most of that time and only recently returned to activity in November, primarily on 80 CW. I'm not really familiar with the issues surrounding the automatic relay of e-mail and don't participate in that mode. I don't think I've even heard one of those stations on the air. If 11306 is driven by special interests in that regard, it's not readily apparent to me. That being said, I don't like the idea of of 11306 creating a ghetto for certain modes by bandwidth because I think it will do nothing to alleviate the existing problem.

The fundamental problem at hand is overcrowding in the lower HF phone subbands and not a lack of space to experiment or innovate. As I see it, there is plenty of room for digital operations in the existing CW subbands. I also like the idea of an FCC enforced subband structure for CW/digital and Phone. Although 90% of us would probably abide by voluntary bandplans, it's the other 10% that will make life miserable for all of us. For that reason alone I think 11305 is flawed although it's a lot better proposal that the ARRL submitted.

I remember submitting my original and 11 copies to the FCC years ago in opposition to the infamous Docket 20777 which would have eliminated AM below 28 MHz. The ARRL by setting up an AM exemption as a parenthetical note seem s to be positioning AM for elimination at a future date. I don't trust their motivations in this proposal.

I also can't agree with the generalization that 80 CW is a vast wasteland. I operate between 3650 and 3730 most nights and I often find it hard to locate a clear frequency or experience QRM. Although the overcrowding found on the 75 meter phone band is absent, the upper section of 80 meter CW is quite well utilized.

I'm not really sure that the CTT proposal is the answer although it appeals to the libertarian instinct in me. I'm more inclined to leave the existing subband structure alone.

73, Jim
WA2AJM

[Glenn NY4NC]

Quite a few of us feel the same way... that's why the CCT proposal is getting the thumbs down. 

I also can't agree with the generalization that 80 CW is a vast wasteland. I operate between 3650 and 3730 most nights and I often find it hard to locate a clear frequency or experience QRM. Although the overcrowding found on the 75 meter phone band is absent, the upper section of 80 meter CW is quite well utilized.

I'm not really sure that the CTT proposal is the answer although it appeals to the libertarian instinct in me. I'm more inclined to leave the existing subband structure alone.

73, Jim
WA2AJM